French and UK courts head for showdown over ICC award
The Paris Court of Appeal found French law applied to the arbitration agreement (Credit: Shutterstock/Ioan Panaite)
In a confrontation reminiscent of the famous Dallah case, the Paris Court of Appeal has upheld an ICC award after finding that French law determined whether the debtor was bound by the arbitration agreement – months after an appeal court in London refused enforcement on the basis that English law applied.
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